Exhibit TT — Case 5:24-cr-00292-PCP, Document 78-2
Summary
This is Exhibit TT to Document 78-2, filed 07/25/25: an e-mail thread from April and May 2025. On April 17, 2025, a paralegal at the Setlich office asks why it is receiving service, saying it does not represent Cassie Will. On April 21, 2025 the paralegal says the office represents Sandra Will only in Will v. United States et al. On May 8, 2025, the government's lawyer writes that he understands Mr. Setlich intends to litigate forfeiture in the criminal proceeding and asks whether he represents Cassie Will-Darnall. Mr. Setlich replies that he is not yet retained but expects to be, and that his office would draft a motion to dismiss the forfeiture order.
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“Exhibit TT — Case 5:24-cr-00292-PCP, Document 78-2.”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-78-2-673fe5c0fa/
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Case 5:24-cr-00292-PCP Document 78-2 Filed 07/25/25 Page 1 of 5
Exhibit TT
Case 5:24-cr-00292-PCP Document 78-2 Filed 07/25/25 Page 2 of 5
From: John Setlich
To: Phillips, Galen (USACAN)
Cc: Jeu, Christopher (USACAN)
Subject: [EXTERNAL] Re: USA v. Cassie Will-Darnall - Case Number CR 24-0292 PCP
Date: Thursday, May 8, 2025 2:23:57 PM
Hello Mr. Phillips,
It is my understanding that I will be representing Ms. Cassie Will in regards to her criminal proceedings.
Although I have not been officially retained as of yet. Specifically, my office will be drafting a motion to
dismiss the forfeiture order recently issued by the Court in the event I am retained, I would like the
opportunity to discuss with you, our motion and possible resolution without filing such motion.
Secondly, it is also my understanding that current counsel will still remain on the case and I will be
associated in as counsel of record as well. However, I will discuss this issue with my client.
Once I’m retained, I will notify you immediately as I am anticipating to be retained by tomorrow. If you would
like to discuss the matter in more detail tomorrow, I am available.
Thank you,
John R. Setlich, Esq.
Attorney
The Law Offices of John R. Setlich, APC
15342 El Prado Road, Suite 200B
Chino, California 91710
Tele: (909) 481-6400
Fax: (909) 481-6433
_______________________________________________________________________________
DISCLAIMER & CONFIDENTIALITY NOTICE: This e-mail message is for the personal and confidential use of the recipient(s) named above. This e-
mail transmission and any documents, files or previous email messages attached to it may contain confidential information that is legally privileged,
covered by the Electronic Communications Privacy Act 18 U.S.C. § 2510-2522. If the reader of this message is not the intended recipient or an agent
responsible for delivering it to the intended recipient. YOU ARE HEREBY NOTIFIED that you have received this document in error and that any
review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this message in error, please notify us
immediately by e-mail and/or by phone at 909.481.6400, and delete the original message and any attachments. NO COMMUNICATION resulting
herein shall create an attorney-client relationship unless a separate retainer agreement, covering these issues, is signed by the Attorney and Client. No
warranty either expressed or implied is made as to the accuracy of any information provided herein. Please be advised that this office DOES NOT
ACCEPT EX PARTE NOTICE via this, or any, electronic communication.
From: Phillips, Galen (USACAN) <Galen.Phillips@usdoj.gov>
Sent: Thursday, May 8, 2025 1:58 PM
To: John Setlich <jrsetlich@setlichlegal.com>
Cc: Jeu, Christopher (USACAN) <Christopher.Jeu@usdoj.gov>
Subject: FW: USA v. Cassie Will-Darnall - Case Number CR 24-0292 PCP
Mr. Setlich,
I represent the government in forfeiture in the above matter. I understand from counsel for the defendant, Cassie
Will-Darnall, that you intend to litigate forfeiture in the criminal proceeding, which is contrary to the below email I
previously received from a paralegal in your office.
If you intend to file a claim concerning forfeiture in the criminal proceeding, please let us know. In addition, if you
represent Cassie Will-Darnall in any capacity, please let us know.
Case 5:24-cr-00292-PCP Document 78-2 Filed 07/25/25 Page 3 of 5
I am available to chat if it would be helpful.
Thank you very much.
Galen A. Phillips
(415) 436-7110
From: Merna Akhnoukh <merna@setlichlegal.com>
Sent: Monday, April 21, 2025 3:27 PM
To: Phillips, Galen (USACAN) <Galen.Phillips@usdoj.gov>
Cc: Caparas, Carolyn (USACAN) [Contractor] <Carolyn.Jusay@usdoj.gov>
Subject: [EXTERNAL] Re: USA v. Cassie Will-Darnall - Case Number CR 24-0292 PCP
Good Afternoon,
Yes our office represents Sandra Will only on case: Will v. United States et al., 24cv9030.
Thank you.
Kind Regards,
Merna Akhnoukh
Paralegal
The Law Office of John R. Setlich, APC
15342 El Prado Road, Suite 200B
Chino, California 91710
Please note our office hours:
Monday- Thursday 8 a.m.- 12 p.m., 1 p.m.- 4p.m.
Friday 8 a.m.- 12 p.m
Tele No: (909) 481-6400
Fax No: (909) 481-6433
merna@setlichlegal.com
DISCLAIMER & CONFIDENTIALITY NOTICE: This e-mail message is for the personal and confidential use of the recipient(s) named above. This e-
mail transmission and any documents, files or previous email messages attached to it may contain confidential information that is legally privileged,
covered by the Electronic Communications Privacy Act 18 U.S.C. § 2510-2522. If the reader of this message is not the intended recipient or an agent
responsible for delivering it to the intended recipient. YOU ARE HEREBY NOTIFIED that you have received this document in error and that any
review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this message in error, please notify us
immediately by e-mail and/or by phone at 909.481.6400, and delete the original message and any attachments. NO COMMUNICATION resulting
herein shall create an attorney-client relationship unless a separate retainer agreement, covering these issues, is signed by the Attorney and Client. No
warranty either expressed or implied is made as to the accuracy of any information provided herein. Please be advised that this office DOES NOT
ACCEPT EX PARTE NOTICE via this, or any, electronic communication. PLEASE NOTE: DUE TO COVID-19, WE WILL NOT BE TAKING ANY
IN PERSON APPOINTMENTS. ALL MEETINGS WILL BE CONDUCTED ELECTRONICALLY AND BY APPOINTMENT ONLY. WE
APOLOGIZE FOR ANY INCONVENIENCE.
From: Phillips, Galen (USACAN) <Galen.Phillips@usdoj.gov>
Sent: Friday, April 18, 2025 9:56 AM
To: Merna Akhnoukh <merna@setlichlegal.com>
Cc: Caparas, Carolyn (USACAN) [Contractor] <Carolyn.Jusay@usdoj.gov>
Subject: RE: USA v. Cassie Will-Darnall - Case Number CR 24-0292 PCP
Merna Akhnoukh:
I received the below email from my colleague, Carolyn (CJ) Caparas. I write in response.
I understand, based on your below representation, that your office does not represent Cassie Will-Darnall in any
capacity. Please let me know if I am mistaken.
Case 5:24-cr-00292-PCP Document 78-2 Filed 07/25/25 Page 4 of 5
We served your office because of its representation of Sandra Will in Will v. United States et al., 24cv9030 (N.D.
Cal.). If your office’s representation of Mrs. Will is limited to just that matter, please let us know, and we will serve
Mrs. Will directly concerning the subject matter.
Have a nice weekend and thank you.
Galen A. Phillips
Assistant U.S. Attorney
Northern District of California
450 Golden Gate Avenue
San Francisco, CA 94102
Desk: (415) 436-7110
galen.phillips@usdoj.gov
From: Merna Akhnoukh <merna@setlichlegal.com>
Sent: Thursday, April 17, 2025 3:22 PM
To: Caparas, Carolyn (USACAN) [Contractor] <Carolyn.Jusay@usdoj.gov>; John Setlich <jrsetlich@setlichlegal.com>
Subject: [EXTERNAL] Re: USA v. Cassie Will-Darnal - Case Number CR 24-0292 PCP
Good afternoon,
Can you please clarify why we are getting this service. As we do not represent Cassie Will.
Thank you.
Kind Regards,
Merna Akhnoukh
Paralegal
The Law Office of John R. Setlich, APC
15342 El Prado Road, Suite 200B
Chino, California 91710
Tele No: (909) 481-6400
Fax No: (909) 481-6433
merna@setlichlegal.com
DISCLAIMER & CONFIDENTIALITY NOTICE: This e-mail message is for the personal and confidential use of the recipient(s) named above. This e-
mail transmission and any documents, files or previous email messages attached to it may contain confidential information that is legally privileged,
covered by the Electronic Communications Privacy Act 18 U.S.C. § 2510-2522. If the reader of this message is not the intended recipient or an agent
responsible for delivering it to the intended recipient. YOU ARE HEREBY NOTIFIED that you have received this document in error and that any
review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this message in error, please notify us
immediately by e-mail and/or by phone at 909.481.6400, and delete the original message and any attachments. NO COMMUNICATION resulting
herein shall create an attorney-client relationship unless a separate retainer agreement, covering these issues, is signed by the Attorney and Client. No
warranty either expressed or implied is made as to the accuracy of any information provided herein. Please be advised that this office DOES NOT
ACCEPT EX PARTE NOTICE via this, or any, electronic communication. PLEASE NOTE: DUE TO COVID-19, WE WILL NOT BE TAKING ANY
IN PERSON APPOINTMENTS. ALL MEETINGS WILL BE CONDUCTED ELECTRONICALLY AND BY APPOINTMENT ONLY. WE
APOLOGIZE FOR ANY INCONVENIENCE.
From: Caparas, Carolyn (USACAN) [Contractor] <Carolyn.Jusay@usdoj.gov>
Sent: Thursday, April 17, 2025 2:44 PM
To: John Setlich <jrsetlich@setlichlegal.com>
Subject: USA v. Cassie Will-Darnal - Case Number CR 24-0292 PCP
Case 5:24-cr-00292-PCP Document 78-2 Filed 07/25/25 Page 5 of 5
Barnard Declaration Exhibit AA-FF (email 5 of 6)
Carolyn Jusay Caparas
FSA Paralegal (Contractor)
United States Attorney’s Office
Asset Forfeiture Unit
415-436-7242
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